EN
.svg)
Since June 28, 2025, the European Accessibility Act (EAA) has required a wide range of digital platforms and services, including websites, apps, e-commerce stores, email campaigns, and digital communications, to be accessible to all users, including those living with disabilities.
From that date forward, all new products placed on the market and services provided to consumers in Portugal must comply with these accessibility requirements.
If you're still getting up to speed on the fundamentals, our first EAA blog post is a great starting point, as it was written specifically to help businesses across Europe understand what the legislation means in practice.
The short answer: no.
Before 2025, the focus across Europe was on preparation and awareness. Now, Portugal's regulators have shifted firmly into active monitoring mode.
Since June 2025, many Portuguese SMEs have attempted to invoke the "disproportionate burden" exemption, a provision that, in theory, allows qualifying companies to limit compliance to what is financially and technically feasible without imposing an unreasonable strain on the business.
However, Portuguese authorities have made it clear that this is not a loophole. To legitimately claim the exemption, companies must conduct and document a thorough financial and technical audit that substantiates the burden. It requires real evidence, not just an assumption.
In terms of what compliance actually looks like, businesses are expected to meet the European standard EN 301 549. For digital services, websites, and apps specifically, this effectively means conforming with WCAG 2.1 Level AA guidelines. Many accessibility experts now recommend targeting WCAG 2.2 to stay ahead of the curve.
One trend worth noting: Portuguese regulators, including ANACOM and Banco de Portugal, appear to be applying an informal grace period approach. Rather than jumping straight to fines, they may first issue a formal notice of non-compliance, giving companies 30 to 90 days to address specific barriers. That said, this is not a guarantee, and it's certainly not a reason to delay.
Unlike some EU member states that have centralised oversight under a single body, Portugal operates a multi-agency regulatory model, with responsibility distributed across sectors. Here are the key authorities to know:
INR – Instituto Nacional para a Reabilitação: The INR has recently updated its website to include a dedicated electronic complaint form specifically for EAA violations. Through this form, individual consumers, NGOs, and even competitors can formally report inaccessible apps, websites, or self-service terminals such as ATMs or ticket machines. This has meaningfully lowered the barrier for reporting.
ANACOM: Portugal's communications watchdog, ANACOM is responsible for defining the technical requirements of electronic communications providers (like MEO, NOS, and Vodafone). They set the rules, and they enforce them within their sector.
Banco de Portugal: When it comes to financial services and EAA compliance, Banco de Portugal is the principal authority. It goes well beyond the physical bank branch — it covers the entire digital and technical infrastructure of retail banking, including online banking platforms, mobile apps, ATMs, and payment services.
Portugal has established a harsh penalty structure for EAA non-compliance, scaled by the severity of the violation:
EAA compliance isn't limited to digital channels. The legislation also extends to physical products and communications.
The last significant deadline was March 15, 2026, which marked the expected adoption date for new harmonised standards covering non-digital information — think physical manuals, packaging, and printed materials. If your digital communications were already up to date, this is the next frontier to address.
EAA compliance in Portugal is no longer a future concern, it's an active regulatory environment with real consequences. The grace period window is narrowing, the complaint process has become more accessible to the public, and the penalties for serious violations are significant.
The good news? Getting compliant doesn't have to be overwhelming, especially when you know exactly where to focus.
To help you get started, we've written an EAA eBook, a resource covering the key digital accessibility requirements your business needs to meet.
It's free, actionable, and designed specifically for businesses operating in Portugal and across the EU.
.png)
